THE DOCTRINE OF STARE DECISIS

IN THE PHILIPPINES

A Term Paper Presented to

Atty. Vanessa Flora

In Partial Fulfillment
of the Requirements
for Statutory Construction
TERM PAPER

by

September 2015
Introduction

The works Judiciary of as well as those of the Legislation is not to be

taken for granted, the laws, as they will be of the public interest, they must
be construed and interpreted in favor of them. The impact of culture affects
how laws are construed and also as how they will be interpreted to be
applied to different case laws. Many are the colonizers that have occupied
the Philippines, and of the experience of dictatorship of Marcos regime. From
them, we adopted many laws, their principles and doctrines, those
occupations and regimes, though mostly tyrannical, the laws they
promulgated, we cannot say are in themselves evil. It was how they were
executed and applied or interpreted, the deciding factor that showed their
unreasonableness and not the law itself. The Cultures we adapt are dynamic
and are intermingling constantly that as the time passes by, it adheres to the
changing setting of the country as quoted by Associate Justice Marvic, Mario
Victor Leonen in one of his lecture in the University of Baguio

From the past, many professionals practicing law and those of have
shown great interest in statutes, observed that the methods that courts use
to interpret statutes are unpredictable and inconsistent, a conclusion that
lawyers and judges agree remains equally true today. While there is heated
disagreement over which doctrines of statutory interpretation are best, there
is widespread consensus that increased consistency would be superior to the
status quo. Lawyers and judges have considered a range of ways to remedy
this situation, but they have overlooked a path to consistency that is tailor-
made to render the unpredictable more predictable, the Stare Decisis
doctrine.

Courts and any Quasi-judicial bodies usually use different legal maxims
for law doctrines or principles. The subject matter of this paper is the
application of one of the most important legal maxims which until the
present time is commonly used. On the other hand, Legal Maxim is an
established principle or proposition. A principle of law universally admitted,
as being a correct statement of the law, or as agreeable to natural reason 1.
Legal maxims are essentially significant in a law profession and also on law
students which be a great help in solving legal problems.

It bestows that there is no secret to observe that lawyers have their

own unique discipline and approach to the resolution of legal problems. Not
surprisingly, there are laws about determining the law. One of the most
important legal maxims is the law of precedent or Stare Decisis. It deals an
important concept applicable in many case law where continues to guide the
bench in keeping with the need to maintain stability in the law.2

With this in mind, this paper is created to provide a link between the
subject and to law students, thus accords the students to a meaningful
understanding on the application and significance of this Doctrine Stare
Decisis. Moreover, it will also serve as a lecture and review material for any
individual who might need the meaningful understanding of this doctrine in
any purposes.

The chapters of this paper begin with the pertinent definitions and
principle applications together with example case laws with detailed solution
to amplify the doctrine for the purpose of effective learning.

Furthermore, the researcher desires to help the UB Law Students in

every way possible so that we may grow and develop professionally in the
achievement of our goal to successfully graduate in Law School and
successfully passing the BAR Exams to become recognized lawyers in the
future.

1 Paul M. Perell, Legal Research (1987)

2 Ibid.
DOCTRINE OF STARE DECISIS

What is the Doctrine of Stare Decisis or Precedent? Descriptions cited:

It is a very desirable and necessary judicial practice that when a court has
laid down a principle of law as applicable to a certain state of facts, it will
adhere to that principle and apply to it all future cases where the facts are
substantially the same. Stare decisis et non quieta movere. Stand by the
decisions and disturb not what is settled.3

Once a case has been decided one way, then another case involving exactly
the same point at issue, should be decided in the same manner.4

Action to invalidate an original certificate of title cannot prosper due to

settled jurisprudence that the title is valid and no longer open to attack.
Matters already decided on the merit cannot be relitigated again and again. 5

The Ruling of the Secretary of Finance, x x x was not binding upon the trial
court, much less upon this tribunal, since the duty and power of interpreting
the laws is primarily a function of the judiciary. Plaintiff cannot be excused
from abiding by this legal principle, nor can it properly be heard to say that
it relied on the Secretarys ruling and that, therefore, the court should not
now apply an interpretation at variance therewith. The rules of stare decisis
is undoubtedly entitled to more respect in the construction of statutes than
the interpretations given by officers of the administrative branches of the
government, even those entrusted with the administration of particular laws;
and yet in Philippine Trust Co. vs. Mitchell (59 Phil., 30), this court refused to

3 Dela Cruz vs. CA, 105 SCAD 95

4 Pines City Educational Center vs. NLRC, 227 SCRA 655

5 J. M. Tuazon & Co., Inc. vs. Mariano, 85 SCRA 644

follow its own doctrine laid down in a former case, saying: More important
than anything else is that the court should be right.6

The doctrine of stare decisis works as a bar only against issues

litigated in a previous case. Where the issue involved was not raised nor
presented to the court and not passed upon by the court in the previous
case, the decision in the previous case is not stare decisis of the question
presently presented.7

The doctrine that, when the court has once laid down a principle of law
as applicable to certain state of facts, it will adhere to that principle and
apply it to all future cases where the facts are substantially the same. 8

Stare decisis simply declares that for the sake of certainty, a

conclusion reached in one case should be applied to those which follow, if
the facts are substantially the same, even though the parties may be
different.9

Foreign Authors;

The operation of the doctrine of stare decisis is best explained by

reference to the English translation of the Latin phrase. Stare decisis
literally translates as to stand by decided matters. The phrase stare
decisis is itself an abbreviation of the Latin phrase stare decisis et non
quieta movere which translates as to stand by decisions and not to disturb
settled matters.

6 Koppel (Phil.) Inc. vs. Yatco, 77 Phil. 946

7 Negros Navigation Co., Inc. vs. CA, 88 SCAD 876

8 Government vs. Jalandoni, 44 OG 1840

9 Prudential Bank & Trust Co. vs. International Asian Co., 40725-R, August 6, 1974
 Basically, under the doctrine of stare decisis, the decision of a higher
court within the same provincial jurisdiction acts as binding authority on a
lower court within that same jurisdiction. The decision of a court of another
jurisdiction only acts as persuasive authority. The degree of persuasiveness
is dependent upon various factors, including, first, the nature of the other
jurisdiction. Second, the degree of persuasiveness is dependent upon the
level of court which decided the precedent case in the other jurisdiction.
Other factors include the date of the precedent case, on the assumption that
the more recent the case, the more reliable it will be as authority for a given
proposition, although this is not necessarily so. And on some occasions, the
judges reputation may affect the degree of persuasiveness of the
authority.10

What the doctrine of precedent declares is that cases must be decided

the same way when their material facts are the same. Obviously it does not
require that all the facts should be the same. We know that in the flux of life
all the facts of a case will never recur, but the legally material facts may
recur and it is with these that the doctrine is concerned.11

Nature and Concept of Stare Decisis

The doctrine is not founded upon a mere rule of practice, changeable

at the pleasure of the courts, but upon the solid basis of justice, and vitally
and essentially affects the rights and interests of defendants. It is a rule
applicable to all questions of law, whether declaring a principle of common
law or the construction of a statute. A deliberate decision on a point of law
given in a case becomes authority in other like cases; it is then the highest
evidence of what the law is applicable to the subject; it should be followed

10 Gerald L. Gall, The Canadian Legal System, 2nd ed. (Toronto: Carswell Legal
Publications, 1983)

11 Glanville Williams, Learning the Law 9th ed. (1973)

unless reversed by a superior court or changed by the legislature, unless the
law was manifestly misunderstood or misapplied in the case decided; and
even then, after long adherence to that error, it may become fixed and
incapable of judicial correction.12

It is a fundamental law that a precedent must be a conclusion, a decision in

a cause; and not a process of reasoning, an illustration, or analogy.13 The
members of a court often agree in a decision, but differ decidedly as to the
reasons and principles by which their minds have been led to a common
conclusion. If the major premise, which is the law of the case, maybe stated
in several forms, and is stated differently by different members of the court
who join in the conclusion, this diversity will impair the force of precedent. A
judicial decision should be regarded as conclusive, not only on the points
presented in argument and expressly decided, but also of every other
proposition necessarily involved in reaching the conclusion expressed. 14

The rule is stare decisis, not a stare opinionibus or even stare responsis.
Opinions are not legally required in most states and in these, a decision
without an opinion may none the less be binding. The opinion may not
logically lead to the decision at all. There may be other and better reasons
for the decision than those in the opinion. There may be several and even
contradictory opinions. In all these situations, the decision is as binding as it
was before. Opinions have only a force called authority which derive it from
the personality and character of the judge, from the standing of the tribunal,
and from the inherent qualities of the opinion.15

12 Sutherland, Statutory Construction, 2nd Ed., Vol2.

13 Wells, The Doctrine of Res Adjudicata & Stare Decisis.

14 Ibid.

15 Max Radin, 33 California Law Review, 1933

Grounds of Stare Decisis

The operation of precedents is based on the legal presumption of the

correctness of judicial decisions. It is an application of the maxim, Res
judicata pro veritate accipitur. A matter once formally decided that they have
been mistaken nor will they open a matter once litigated and determined.
That which has been delivered in judgment must be taken for established
truth. For in all probability it is true in fact, and even if not, it is expedient
that it should be held as true none the less. When therefore, a question has
been judicially considered and answered, it must be answered in the same
way in all subsequent cases in which the same question again arises. Only
thru this rule can that consistency of judicial decision be obtained, which is
essential to the administration of justice. 16 By this reliance in the law is
attained.17

A precedent therefore, is a judicial decision which contains in itself a

principle. This underlying principle is often termed ratio decidendi which
alone has the force of law as regards the world at large.18

Classes of Precedents

Precedents may be declaratory, one which is merely the application of an

already existing rule of law or an original precedent, one which creates and
applies a new rule. In the former case, the rule is applied because it is
already a law; in the latter case, it is law for the future because it is now
applied. The legal authority of each is exactly the same. 19

16 Salmond, Jurisprudence, 7th Ed.

17 Halcomb v. Bonnel, 32 Mich. 8

18 Mina, The Doctrine of Stare Decisis and the Supreme Court of the Philippine Islands.

19Ibid.
Precedents are further divisible into authoritative and persuasive. These two
classes differ in respect of the kind of inference which they exercise upon the
future course of administration of justice. An authoritative precedent is one
which judges must follow regardless of their beliefs or convictions. It is
binding upon them and excludes their judicial discretion. Persuasive when
the judges are under no obligation to follow although they may attach
weight and merit to them as may be warranted. Generally, decisions of
superior courts are authoritative; those of lower courts, merely persuasive. 20

Authoritative precedents are of two kinds: either absolute or conditional. In

the first case, the decision is unconditionally followed without question
however unreasonable or erroneous it may be considered to be. It has a
legal claim to implicit and unquestioning obedience. In the second case, the
precedent possesses merely conditional authority when the courts possess a
certain limited power of disregarding it.21

Application of Stare Decisis

The following rules are generally recognized for the application of

precedents: a) Each court is bound by the decision of courts above it; b) Any
relevant judgment of any court is a strong argument entitled to respectful
consideration; c) A judgment is authoritative only as to its ratio decidendi;
d) a precedent is not abrogated by lapse of time; e) Ancient precedents are
not in practice, commonly applicable to modern circumstances. These rules
are practical and of salutatory effect.22

No absolute rule can be given as to when stare decisis is imperative,

so much depends on the particular case in which it may be invoked. It must

20 Ibid.

21 Ibid.

22 Allen, Law in the Making, 2nd Ed.

be said however, that courts are not required in the exercise of their wide
judicial discretion, to overturn principles which have been considered and
acted upon as correct, and thereby disturb contracts and property and
involve everything in inexplicable confusion.23

Limitation to the Doctrine of Stare Decisis

The doctrine of stare decisis is not altogether absolute or inflexible. In some

instances it can be set aside. But even in such cases the subsequent judges
do not pretend to make a new law, but to vindicate the old one from
misrepresentation. For if it be found that the former decision is manifestly
absurd or unjust, it is declared, not that such a statement was a bad law,
but that what is not reason is not law. In that case, the interpretation
becomes the spirit of the old law.24

In order that a court is justified in disregarding a conditionally authoritative

precedent, two conditions must be fulfilled. In the first place, the decision
must be a wrong decision, that is contrary to law, when there is already in
existence an established rule of law on the point in question, and the
decision fails to conform to it. In the second place, the decision must be a
wrong decision that is wrong being contrary to reason. When there is no
settled law to declare and follow, the courts may make law for the occasion,
and in so doing, it is their duty to follow reason, and so far as they fail to do
so, their decisions are wrong and the principles involved in them are
defective authority. Unreasonableness is one of the vices of a precedent no
less than of a custom and of certain forms of subordinate legislation. 25

23 Mina, The Doctrine of Stare Decisis and the Supreme Court of the Philippine Islands.

24 Blackstone, Laws of England, 4th Ed.

25 Salmond, Jurisprudence, 7th Ed.

Another limitation should also be born in mind. The doctrine of stare decisis,
is only applicable, in its full force, within the territorial jurisdiction of the
courts making the decision, since there alone can such decisions be regarded
as having established any rules. Rulings made under a similar legal system
elsewhere may be cited and respected for their reasons, but are not
necessarily to be accepted as guides except in so far as those reasons
commend themselves to the judicial mind.26

Legal Argument in the Application of Stare Decisis

Thus noting the court ranking of the judge before whom the lawyer will
be appearing and guided by the doctrine of stare decisis, the lawyer will then
prepare his or her argument. Usually, the best position for the lawyer occurs
when there is a precedent case supporting his or her clients case. The
lawyer will then argue that the court is either bound, or that the court, if not
actually bound, ought to be persuaded by the precedent case to find in the
clients favour. In his or her research, the lawyer will therefore look for cases
with results which support the clients position and the lawyer will prepare to
argue that the ratio decidendi of those precedent cases covers the facts of
the case at bar. However, just locating and evaluating the prospects of
precedent cases is not easy since it is often difficult to determine and
articulate the authority of a case. Moreover, skill is necessary to analyze and
organize the material facts of both the precedent case and the case at bar.
That said, more difficult problems of legal reasoning and legal argument
occur when the lawyer is unable to find a close case or any case at all or,
worse yet, when a case presents itself which appears to be unfavourable.
How does the lawyer deal with these problems?

To get around an apparently unfavourable case, there are a number of

tools and techniques available to the lawyer. The lawyer may not simply
ignore the unfavourable case and hope that the other side does not discover
26 Cooley, Constitutional Limitations, 7th Ed.
the authority. This is unethical and with respect it may be submitted that it is
also unethical and intellectually dishonest for a judge in deciding a case to
simply ignore a precedent case which stands in the way of the decision that
the judge wants to make. This is not to say that lawyers and judges must
deal with every case that remotely touches on a subject but only that there
should be an honest effort to play by the rules.

The techniques that are available follow as a consequence of accepting

and then manipulating the doctrine of stare decisis. The techniques structure
and direct the lawyers legal reasoning and argument. The following are
generally recognized:

The lawyer can argue that the precedent case does not stand for the
legal proposition for which it has been cited. In other words, the
lawyer articulates the ratio decidendi of the case differently.
The lawyer can argue that while the precedent case does articulate the
legal proposition for which it has been cited, nevertheless the
proposition was obiter dicta (things said by the way). Subject to an
exception for considered pronouncements of the law by appellate
courts, comments by the judge which are not part of the ratio
decidendi are obiter dicta and are theoretically not binding in a
subsequent case. The exception is that where an appellate court
expresses a considered opinion on a point of law then such ruling is
binding on the lower courts notwithstanding that it was not absolutely
necessary to rule on the point in order to dispose of the appeal. It
should be noted that if a judge rests his decision on two different
grounds neither can be characterized as obiter dictum.
The lawyer can argue that while the precedent case does stand for the
legal proposition for which it has been cited, the case has been
effectively overruled by a decision of a high court or by the
introduction of a new statute.
 The lawyer can argue that while the precedent case does stand for the
legal proposition for which it has been cited, the case at bar is
different; that is, the cases are factually distinguishable. Non-
restrictive distinguishing occurs where a court accepts the expressed
ratio decidendi of the earlier case, and does not seek to curtail it, but
finds that the case before it does not fall within this ratio decidendi
because of some material difference of fact. Restrictive distinguishing
cuts down the expressed ratio decidendi of the earlier case by treating
as material to the earlier decision some fact, present in the earlier
case, which the earlier court regarded as immaterial.27
Where the case being relied upon has a built in public policy factor, the
lawyer who wishes to distinguish the case may argue that public policy
has changed and while the legal principle of the precedent case is still
good law, it is distinguishable because of the change of
circumstances. A series of decisions based upon grounds of public
policy, however eminent the judges by whom they were delivered,
cannot possess the same binding authority as decisions which deal
with and formulate principles which are purely legal.
The lawyer can argue that while the precedent case does stand for the
legal proposition for which it has been cited, there is another
precedent of equal weight which stands for the opposite proposition.
The lawyer then goes on to argue that it is that other case which the
court should follow. This type of argument is related to but in the end
result different from the per incuriam argument because it does not
necessarily challenge either decision as having been given per
incuriam. The rule is rather that the court may decide which one of the
conflicting decisions to follow.

The above seven types of legal argument are the principle techniques
used to get around an apparently binding precedent and we can turn next to

27 Glanville Williams, Learning the Law 9th ed. (1973)

the problem of not being able to find a precedent case. Because there is
considerable room for imagination and creativity in responding to this
problem, it is more difficult to identify the main techniques. Nevertheless,
some typical responses may be identified. Below we will consider three
classical types of legal reasoning used in these circumstances. Again the
doctrine of stare decisis, this time in spirit, may be noted:

Where a lawyer cannot find a binding precedent, he or she may rely on

a non-binding precedent from another jurisdiction. While not obliged to
do so, the court may be impressed with or be persuaded by the
reasoning and be prepared to adopt the rule established by the foreign
case. However, care must be taken in employing this technique
because it often necessitates reviewing the foreign law to determine
whether there may be underlying differences in principles which qualify
or which may diminish the persuasiveness of the foreign case.
Where a lawyer cannot find a binding precedent, he or she may form a
legal argument from first principles. This approach identifies legal
principles from decided cases and argues that while the factual
circumstances of the cases may appear different, analytically they are
the same. This kind of legal argument is often used with respect to
determining the measure of damages.
Where a lawyer cannot find a precedent he or she can go beyond first
principles and instead develop an argument that the decided cases
have evolved to a general principle which covers the immediate case.
This is a very sophisticated and creative type of argument. It is the
kind of argument in which common law lawyers and judges take
particular pride.
Presentation of Case Laws

TALA REALTY SERVICES CORP VS. BANCO FILIPINO SAVINGS AND

MORTGAGE BANK

GR 137980 JUNE 20, 2000

FACTS:

Respondent has a legal problem with regard to its real estate holdings.
The law requires that respondents real estate holdings should only be 50%
of its net worth. This constituted a bar to the planned expansion of
respondent. To solve the predicament of the respondent, it created a
separate entity, which is petitioner, wherein the existing branch sites would
be unloaded and the said petitioner would also acquire new branch sites for
respondent and lease it to the latter. Pursuant to the agreement between the
two parties, the petitioner acquired properties from respondent and then
leased them to the latter. It was a part of the agreement that petitioner only
holds properties for the respondent and that the said properties would be
returned to respondent at its pleasure.

There came a time when there was a disagreement between the two
parties on which of the 2 lease contracts of lease presented by each party
governs them. Petitioner contends that it is the 11-year contract while the
other presents a 20-year contract. Both contracts have been allegedly
notarized and executed on the same date.

Using the 11-year contract as basis, the petitioner filed a petition for
ejectment against respondent. However, the petitioner lost in all its cases
and appealed the case to the Court of Appeals. The CA mentioned in its
decision that the lower courts erred in refusing to exercise jurisdiction, when
the issue of possession and issue of validity of contract is intertwined.
Nonetheless, it dismissed the petition to maintain judicial consistency and
stability as other ejectment cases like the one at bar have already been
decided on. Petitioner filed MR and was granted by ordering respondent to
pay the unpaid rentals. Subsequently, the respondent filed an MR and the CA
reversed its decision, which made petitioner file an appeal to the SC saying
that the CA erred in considering the ruling of the court in another case as
the law of the case between petitioner and respondent. Respondent then
said that only decisions of the SC establish jurisprudence or doctrines.

ISSUE:

Whether or not the principle of stare decisis should be applied to the case at
bar even if the parties and properties involved are different?

HELD:

The stare decisis principle should be upheld.

There had been previously a decision by the SC involving the same

parties but different property, wherein it was upheld and decided that the 20
-year lease contract should prevail. It even mentioned in its decision that the
11-year contract was forged and simulated as it was never really notarized
nor submitted to the Central Bank, as required by law.

In the light of the aforementioned decision, the Court doesnt have any
option but to uphold the 20-year lease contract, following the principle of
stare decisis et non quieta movere (follow past precedents and do not
disturb what has been settled).

It is the policy of the Court to maintain judicial stability in accordance

to stare decisis. As in this case, the same questions relating to the same
even have been put forward by parties similarly situated as in a previous
case litigated and decided by a competent court, the rule of stare decisis is a
bar to any attempt to relitigate the same issue. The ruling is final even as to
parties who are strangers to the original proceedings and not bound by the
judgment under the res judicata doctrine. Stare decisis should apply if the
facts are substantially the same even if the parties may be different.

xxx

JM TUASON AND CO. INC. VS. MARIANO

GR 3314O OCTOBER 23, 1978

FACTS:

Respondents filed a complaint praying that they be declared owners of

a certain parcel of land located in Rizal. They alleged that their father
acquired this land with a Spanish title. They alleged that petitioner
fraudulently or included the land in an original certificate of title. They also
alleged that transfer certificates of title were issued to petitioners irregularly.
Given such, they are praying that the titles derived therefrom be declared
void due to irregular proceedings.

The lower court issued an order requiring the parties to produce

documents to support their allegations. With this, the petitioner filed a
petition for certiorari and prohibition, inter alia, that the lower court be
ordered to dismiss the complaint and enjoined from proceeding the case.

Before this present complaint, the respondents had already filed a

complaint questioning the validity of the titles of petitioner, wherein the
lower court and the SC upheld its validity.

ISSUE:

Whether or not the titles can still be questioned by respondents?

HELD:

They cannot anymore question. Considering the principle of stare

decisis, the respondents cannot anymore continue with their action without
eroding the long settled holding of the courts of the validity of the titles and
no longer open to attack.

It is against public policy that matters already decided on the merits

be relitigated again and again, consuming the courts time and energies at
the expense of other litigants.

xxx

EL PUEBLO DE FILIPINAS VS. MARQUIDA

GR 953, SEPTEMBER 18, 1947

FACTS:

The case at bar is an appeal of respondent of the decision rendered by

the lower court, finding him guilty of the crime of treason.

Respondent was charged with the crime of treason for allegedly

helping out Japanese occupants in arresting and abducting of Filipinos who
were thought to be guerrillas. He was found guilty by the lower court, using
the testimony of many witnesses.

It is alleged that respondent cannot be found of guilty of treason due

to the indetermination of his citizenship or nationality. Following the doctrine
of stare decisis, wherein in a prior case, 2 were not found to be citizens since
during the time of birth, a limitation on the application of jus soli for
citizenship was established.

ISSUE:

Whether or not the principle of stare decisis should be applied to the case at
bar?
HELD:

No. Stare decisis doesnt work up to the extent of perpetuating an

error. If it is found that in the past there was a mistake, stare decisis
shouldnt bar the Court from correcting itself.

xxx

JOSE TAN CHONG VS. SECRETARY OF LABOR

GR 47616 SEPTEMBER 16, 1947

&

LAM SWEE SANG VS. THE COMMONWEALTH OF THE PHILS.

GR 47623 SEPTEMBER 16, 1947

FACTS:

Petitioners in the two cases are both of born of a Chinese father and a
Filipino mother. The first petitioner was granted writ of habeas corpus since
he was declared to be a Filipino citizen due to the doctrine of jus soli, which
says that when one is born in a country, he acquires the citizenship of that
country. Such has been said to be the same with the second petitioner.
Second petitioners petition for naturalization was dismissed since he no
longer needed to be naturalized. The Solicitor General opposed such
decision, saying that the two are not citizens of the Philippines pursuant to
the laws existing during their time of birth.

Before this, the Court, with regard to cases like this, used the principle
of jus soli, adopted from the US Constitution, which says that all those born
and naturalized in the US and placed under its jurisdiction is a citizen of the
US.
 The Solicitor General mentioned that the principle of jus soli wasnt
extended to the Philippines. In a previous case wherein jus soli was used
was based in a prior case, which mentioned the principle of jus soli but
wasnt actually the issue at hand. Furthermore, if ever the principle of jus
soli was extended, it had its limitations. The law that prevailed then
mentioned that if one was born after a certain date and in accordance with
other conditions, which would only be the time when one is considered a
citizen. Otherwise, they are not to be considered citizens.

ISSUE:

Whether or not precedents regarding citizenship should be upheld,

following the principle of stare decisis?

HELD:

No, the principle of stare decisis doesnt mean being blind adherence
to precedents. Even if the doctrines laid down have been followed for years,
if it has been found to be contrary to law, it should be abandoned or
reconsidered. Principle of stare decisis shouldnt be applied if there is conflict
between law and precedent.

Given that the law enforced during the time of birth of two petitioners
doesnt allow them to be citizens of the Philippines, even if precedence tells
that they be allowed to be citizens of the Philippines, cannot be declared
Filipino citizens.
CONCLUSION

The Judiciary, in practice is the court which applies and interprets the
enacted laws. The power, of which is vested to one Supreme Court and lower
courts as established by the law. In this branch of the government, cases are
settled, through which Judicial Opinions are heard. The quality of judicial
opinion, determines the quality of a court on how they apply or interpret
laws. A law needs only to be applied if the law is clear and unequivocal, and
while they will need to interpret it if the law is vague or ambiguous.

Justices of the Supreme Court and judges of the lower courts, in their
conduct of their function should practice with utmost care their duties. They
are the ones that will be responsible for the final interpretation, from
rigorous analysis of facts, they will base their decisions. Their job in doing
so, are very important, by the doctrine of stare decisis where cases decided
are used as basis for cases that are of similar situation. Be it that in another
case, different decision is given, completely different and opposite from the
former, this will be become an impairment of its integrity. Thus, we can say,
Judiciary as not only concerned with applying but also with interpretation
and construction of case laws. As quoted by Justice Marvic Leonen there is
no perfect interpretation, hence, we cannot accept them as evidence, being
not conclusive but rather ardently persuasive.

The doctrine of stare decisis is the authority of judicial decisions as

precedents in subsequent litigations. To afford to the citizen a sound
administration of justice is the justification of its existence. Certainty,
stability, and symmetry in any system of jurisprudence are the necessary
results of its application. But the rule is not inflexible, it may be disregarded
when the evils of adherence are manifestly greater than those of departure.